OFAC Expands Iran Sanctions, Revises Cuba Rules, and Streamlines Enforcement in September 2026

The Office of Foreign Assets Control took a series of sanctions actions in September 2026, including designating many Iranian airlines, suspending certain aviation and humanitarian-related general licenses, sanctioning Russia’s VTB Bank, and applying a presumption of denial to Iran-specific license requests. New Cuba regulations implementing Executive Order 14404 restrict indirect dealings with Cuba Restricted List entities, end the U-turn authorization, and remove group people-to-people and professional-meeting travel permissions as of September 30, 2026. OFAC also ended the Ethiopia program, amended terrorism-list sanctions rules after Syria’s state sponsor designation was rescinded, delisted certain parties under Belarus, Russia, and DRC programs, consolidated penalty and enforcement procedures into 31 C.F.R. Part 505, and adjusted licensing for Lukoil International GmbH and Venezuela.
In September 2026, OFAC designated many Iranian airlines and foreign aviation support companies, suspended several aviation and humanitarian-related general licenses, and adopted a denial presumption for Iran-specific license applications. It also sanctioned VTB Bank and targeted an Iranian digital-asset exchange.
New Cuba rules under EO 14404 took effect September 30, restricting indirect dealings with Cuba Restricted List entities, ending the U-turn permission, and removing collective people-to-people and professional meeting travel approvals. OFAC also closed the Ethiopia program, revised terrorism-list rules after Syria’s state sponsor designation was rescinded, delisted selected Belarus, Russia, and DRC parties, consolidated penalty procedures into 31 C.F.R. Part 505, and adjusted Lukoil and Venezuela licensing.
The measures may affect Iranian aviation, trade intermediaries, humanitarian organizations, Cuba-focused travelers, financial institutions, and companies with Russia, Venezuela, Belarus, or DRC exposure. Compliance costs could rise, transactions may slow or stop, and some humanitarian or professional travel may become harder. Enforcement consolidation may make penalties clearer but could also increase risks for firms. These are possible consequences, not predictions.